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GRIFFIN v. COMMISSIONER

Docket No. 31824-85.

56 T.C.M. 1560 (1989)

T.C. Memo. 1989-130

Jeffrey E. Griffin and Barbara B. Griffin v. Commissioner.

United States Tax Court.

Filed March 29, 1989.

Attorney(s) appearing for the Case

Thomas W. Tucker, 650 Poydras St., New Orleans, La., for the petitioners. Linda K. West, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

In a timely statutory notice of deficiency, respondent determined a deficiency in petitioners' 1981 Federal income tax in the amount of $16,427.11. Respondent also determined that the deficiency was attributable to a tax motivated transaction under section 6621(c)1 and that an increased interest rate applies to the deficiency.

After concessions, the sole issue we must...

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